I am very concerned about the broken decisionmaking process your agencies are using to approve new genetically engineered (GE) crops and their associated pesticide formulations. Last year’s approval of Monsanto’s “Xtend” soy and cotton seeds (engineered for use with glyphosate and the herbicide dicamba) is just one example of real-world impacts — like damage from herbicide drift — not being fully taken into account.

As was predicted by USDA’s own data, Xtend crops are driving up the use of drift-prone dicamba. The threat of crop damage for specialty crop farmers in the Midwest is very real, and in the first growing season we’re already hearing reports of dicamba-related crop damage from farmers in Arkansas, Tennessee and Missouri.

Monsanto says they’ve reformulated dicamba to be less drift prone — but that formulation is still awaiting EPA approval. Even when it is available, there’s no guarantee that the older, cheaper and more damaging version of the chemical won’t continue being used in the field.

The decision to approve dicamba-resistant crops reflects your agencies’ fragmented, incomplete framework to assess on-the-ground impacts of GE crops and their related pesticides. Neither agency currently considers potential crop damage, and no one is asking the most important question of all: Why would we put a product on the market that will make the superweed problem worse, rather than solve it?

We need a regulatory system — and Coordinated Framework — that takes a rigorous approach to pesticides and GE crops that values small farmers and rural communities, and stands strong in the face of corporate pressure.